US Extends Time for Potential Revocation of Sudan Sanctions

Written by Douglas Maag

As we previously reported, (click here to view the article) , on January 13 of this year President Obama issued Executive Order 13761 (E.O. 13671), which resulted in issuance of a license authorizing all transactions prohibited under the US-Sudan sanctions regime.

E.O. 13671 also provided that the US would revoke its Sudan sanctions altogether on July 12, 2017, provided that the State Department publishes a report by that date stating that the Government of Sudan (GOS) has sustained the positive actions that gave rise to issuance of the license, including maintaining a cessation of hostilities in conflict areas in Sudan, improving humanitarian access throughout Sudan, and maintaining its cooperation with the US on addressing regional conflicts and the threat of terrorism.

President Trump has now issued an executive order extending the State Department's review period for three month, until October 12, 2017.

According to a related State Department press statement:

The United States will revoke the sanctions if the GOS is assessed to have sustained progress in these areas at the end of the extended review period. The general license issued by the Treasury Department’s Office of Foreign Assets Control, which became effective on January 17, 2017, remains in place and broadly authorizes U.S. persons to process transactions involving persons in Sudan; engage in imports from and exports to Sudan; and engage in transactions involving property in which the GOS has an interest.

It appears that this action arises not from particular concerns with the GOS, but rather because the State Department was simply unable to complete its review in the time originally allotted. Indeed, the State Department press statement noted:

While we recognize that the GOS has made significant, substantial progress in many areas, the Administration has decided that some more time is needed for this review to establish that the GOS has sustained sufficient positive actions across all areas listed in E.O. 13761.

Thus, albeit delayed, it appears that the planned revocation of the US-Sudan sanctions remains in the offing.